From:	Angela Cullen/AA/USEPA/US

To:	"Achanta, Chandana L." <Chandana_L._Achanta@omb.eop.gov>

Cc:	Byron Bunker/AA/USEPA/US@EPA, james.tamm@dot.gov,
Angel.Jackson@dot.gov, lixin.zhao@dot.gov, Ryan.Harrington@dot.gov, Paul
Balserak/DC/USEPA/US@EPA, Ann Wolverton/DC/USEPA/US@EPA, Donald
Kopinski/AA/USEPA/US@EPA, Kathryn Sargeant/AA/USEPA/US@EPA,
rebecca.yoon@dot.gov, Cheryl Bynum/AA/USEPA/US@EPA

Date:	10/08/2010 02:29 PM

Subject:	Heavy Duty Response to OMB Request



Chandana, 

In response to yesterday's call, we have included two attachments.   

The first is RIA Chapter 6.  The chapter discusses all of the
alternatives and includes additional language explaining the two new
alternatives (6a and 6b).  Once we have agreement on the language in the
RIA, then we will carry it into the preamble. 

The second contains two tables which list the individual technology
effectiveness and cost for each subcategory. 

Please let us know if you have any questions or concerns. 

Thank you. 

Angela 

U.S. Environmental Protection Agency

Office of Transportation & Air Quality

Assessment and Standards Division

2000 Traverwood Drive

Ann Arbor, MI  48105

Phone: (734) 214-4419

Fax: (734) 214-4050

Email: cullen.angela@epa.gov 

 

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc274300423"  Chapter 6:
Results of Proposed and Alternative Standards	  PAGEREF _Toc274300423 \h
 6-2  

  HYPERLINK \l "_Toc274300424"  6.1	What Are the Alternatives that the
Agencies Considered?	  PAGEREF _Toc274300424 \h  6-2  

  HYPERLINK \l "_Toc274300425"  6.1.1	Alternative 1: No Action	  PAGEREF
_Toc274300425 \h  6-2  

  HYPERLINK \l "_Toc274300426"  6.1.2	Alternative 2: Engine Only	 
PAGEREF _Toc274300426 \h  6-3  

  HYPERLINK \l "_Toc274300427"  6.1.3	Alternative 3: Class 8 Combination
Tractors	  PAGEREF _Toc274300427 \h  6-4  

  HYPERLINK \l "_Toc274300428"  6.1.4	Alternative 4: Engines and Class 7
and 8 Tractors	  PAGEREF _Toc274300428 \h  6-6  

  HYPERLINK \l "_Toc274300429"  6.1.5	Alternative 5: Engines, Class 7
and 8 Tractors, and HD Pickup Trucks and Vans	  PAGEREF _Toc274300429 \h
 6-7  

  HYPERLINK \l "_Toc274300430"  6.1.6	Alternative 6: Engines, Tractors,
and Class 2b through 8 Trucks.	  PAGEREF _Toc274300430 \h  6-8  

  HYPERLINK \l "_Toc274300431"  6.1.7	Alternative 7: Engines, Tractors,
Trucks, and Trailers.	  PAGEREF _Toc274300431 \h  6-13  

  HYPERLINK \l "_Toc274300432"  6.1.8	Alternative 8: Engines, Tractors,
Trucks, and Trailers with Hybrid Powertrains	  PAGEREF _Toc274300432 \h 
6-14  

  HYPERLINK \l "_Toc274300433"  6.2	How Do These Alternatives Compare in
Overall GHG Emissions Reductions and Fuel Efficiency and Cost?	  PAGEREF
_Toc274300433 \h  6-15  

 

Results of Proposed and Alternative Standards

The heavy-duty truck segment is very complex. The sector consists of a
diverse group of impacted parties, including engine manufacturers,
chassis manufacturers, truck manufacturers, trailer manufacturers, truck
fleet owners and the air breathing public. The proposal the agencies
have laid out today is largely shaped to maximize the environmental and
fuel savings benefits of the program respecting the unique and varied
nature of the regulated industries.  In developing this proposal, we
considered a number of alternatives that could have resulted in fewer or
potentially greater GHG and fuel consumption reductions than the program
we are proposing.  This section summarizes the alternatives we
considered.  We welcome comments on all of these alternatives.

What Are the Alternatives that the Agencies Considered?

In developing alternatives, NHTSA must consider EISA's requirement for
the MD/HD fuel efficiency program noted above. 49 U.S.C. 32902(k)(2) and
(3) contain the following three requirements specific to the MD/HD
vehicle fuel efficiency improvement program: (1) The program must be
“designed to achieve the maximum feasible improvement”; (2) the
various required aspects of the program must be appropriate,
cost-effective, and technologically feasible for MD/HD vehicles; and (3)
the standards adopted under the program must provide not less than four
model years of lead time and three model years of regulatory stability.
In considering these various requirements, NHTSA will also account for
relevant environmental and safety considerations.

Each of the alternatives proposed by NHTSA and EPA represents, in part,
a different way the agencies could establish a HD program pursuant to
EISA and the CAA. The agencies are proposing Alternative 6.  The
alternatives below represent a broad range of approaches under
consideration for setting proposed HD vehicle fuel efficiency and GHG
emissions standards.  The alternatives that the agencies are proposing,
in order of increasing fuel efficiency and GHG emissions reductions,
are:

Alternative 1: No Action

A “no action” alternative assumes that the agencies would not issue
a rule regarding a MD/HD fuel efficiency improvement program, and is
considered to comply with National Environmental Policy Act (NEPA) and
to provide an analytical baseline against which to compare environmental
impacts of the other regulatory alternatives.  The agencies refer to
this as the “No Action Alternative” or as a “no increase” or
“baseline” alternative.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  1   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  1  Estimated Fleet-Wide Fuel Efficiency
by Model Year for Alternative 1 (Baseline) [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.6	6.6	6.6	6.6	6.6

HD Pickups and Vans- diesel	6.9	6.9	6.9	6.9	6.9	6.9

Vocational –gasoline	11.4	11.3	11.3	11.3	11.3	11.3

Vocational – diesel	10.2	10.2	10.2	10.2	10.2	10.2

Comb. tractors	20.2	20.2	20.2	20.2	20.2	20.2

As described in Chapter 5, this no-action alternative is considered the
reference case.

Alternative 2: Engine Only

The EPA currently regulates heavy-duty engines, i.e., engine
manufacturers, rather than the vehicle as a whole, in order to control
criteria emissions.  Under Alternative 2, the agencies would similarly
set engine performance standards for each vehicle class, Class 2b
through Class 8, and would specify an engine cell test procedure, as EPA
currently does for criteria pollutants. HD engine manufacturers would be
responsible for ensuring that each engine could meet the applicable
vehicle class engine performance standard when tested in accordance with
the specified engine cell test procedure. Engine manufacturers could
improve HD engines by applying the combinations of fuel efficiency
improvements and GHG emissions reduction technologies to the engine that
they deem best achieve that result.

For this scenario, we assumed the following CO2 reductions stated in  
REF _Ref267644982 \h  Table 6-2 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  2   STYLEREF 1 \s 
6 -  SEQ Table \* ARABIC \s 1  2  Estimated Possible Reductions in
Engine CO2 Emission Rates in Alternative 2 

GVWR Class	Fuel	Model years	CO2 Reduction from Reference Case

HHD (8a-8b)	Diesel	2014-2016	3%



2017+	6%

MHD (6-7) and LHD 4-5	Diesel	2014-2016	5%



2017+	9%

	Gasoline	2016+	5%

LHD 2b-3	Gasoline	2016+	5%

	Diesel	2016+	9%



Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  3   STYLEREF 1 \s 
6 -  SEQ Table \* ARABIC \s 1  3  Estimated Fleet-Wide Fuel Economy
Efficiency by Model Year for Alternative 2 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.6	6.6	6.3	6.3	6.3

HD Pickups and Vans- diesel	6.9	6.9	6.9	6.3	6.3	6.3

Vocational –gasoline	11.4	11.3	11.3	10.8	10.8	10.8

Vocational – diesel	10.2	9.9	9.9	9.9	9.7	9.7

Comb. tractors	20.2	19.6	19.6	19.6	19.0	19.0



Alternative 3: Class 8 Combination Tractors

Combination tractors consume the largest fraction of fuel within the
medium- and heavy-duty truck segment.  Tractors also offer significant
potential for fuel savings due to the high annual mileage and high
vehicle speed of typical trucks within this segment, as compared to
annual mileage and average speeds/duty cycles of other vehicle classes.
This alternative would set performance standards for both the engine of
Class 8 vehicles and the overall vehicle efficiency performance for the
Class 8 combination tractor segment.  Under Alternative 3, the agencies
would set an engine performance standard, as discussed under Alternative
2, for Class 8 tractors.  In addition, Class 8 combination tractor
manufacturers would be required to meet an overall vehicle performance
standard by making various non-engine fuel saving technology
improvements.  These non-engine fuel efficiency and GHG emissions
improvements could be accomplished, for example, by a combination of
improvements to aerodynamics, lowering tire rolling resistance,
decreasing vehicle mass (weight), reducing fuel use at idle, or by
adding intelligent vehicle technologies.  Compliance with the overall
vehicle standard could be determined using a computer model that would
simulate overall vehicle fuel efficiency given a set of vehicle
component inputs.  Using this compliance approach, the Class 8 vehicle
manufacturer would supply certain vehicle characteristics (relating to
the categories of technologies noted immediately above) that would serve
as model inputs.  The agencies would supply a standard Class 8 vehicle
engine's contribution to overall vehicle efficiency, making the engine
component a constant for purposes of compliance with the overall vehicle
performance standard, such that compliance with the overall vehicle
standard could only be achieved via efficiency improvements to
non-engine vehicle components.  Thus, vehicle manufacturers could use
any combination of improvements of the non-engine technologies that they
believe would best achieve the Class 8 overall vehicle performance
standard.  

This alternative in NHTSA’s scoping notice involves regulating Class 8
combination tractors only.  For this scenario, we assumed the following
CO2 reductions stated in   REF _Ref273957414 \h  Table 6-4  and road
load improvements stated in   REF _Ref273957428 \h  Table 6-5 .  REF
_Ref267645080 \h  \* MERGEFORMAT  

Table 6-4  and road load improvements stated in   REF _Ref267645094 \h 
\* MERGEFORMAT  

Table 6-5 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  4   STYLEREF 1 \s 
6 -  SEQ Table \* ARABIC \s 1  4  Estimated Possible Reductions in Class
8 Engine CO2 Emission Rates in Alternative 3

GVWR class	Fuel	Model years	CO2 Reduction from Reference Case

HHD (8a-8b)	Diesel	2014-2016	3%



2017+	6%



Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  5   STYLEREF 1 \s 
6 -  SEQ Table \* ARABIC \s 1  5  Estimated Reductions in Rolling
Resistance and Aerodynamic Drag Coefficients for Model Years 2014 and
Later in Alternative 3

Truck type	Reduction in tire rolling resistance coefficient from 2010 MY
Reduction in aerodynamic drag coefficient from 2010 MY

Combination long-haul	8.4%	7.2%

Combination short-haul	7.0%	5.3%

To run MOVES for this alternative, the “samplevehiclepopulation”
table was altered such that only the Class 8 tractors would be output in
the combination long-haul and combination short-haul source types. 
These source types normally include Class 7 trucks also.  Since MOVES
outputs results by source/vehicle type and not engine class, two runs
were performed for combination tractors.  The first run included the
database with the above changes and with the Class 7 population set to
zero.  The second run did not include the above changes but with the
Class 8 population set to zero.  The results from these two runs gave
Class 8 combination tractors affected by this alternative and Class 7
combination tractors not affected by this alternative.  The two runs
were combined, preserving the total Class 7/8 combination tractor
population, while applying the changes only to the Class 8 combination
tractors. 

For the purpose of this analysis, it was assumed that 100 percent of
Class 8 combination long-haul tractors model year 2014 and later use
APUs during extended idling.  This assumption is based on the
expectation that manufacturers will use APUs to meet the vehicle GHG
standard for Class 8 combination long-haul tractors.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  6   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  6  Estimated Fleet-Wide Fuel
EfficiencyEconomy by Model Year for Alternative 3 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.6	6.6	6.6	6.6	6.6

HD Pickups and Vans- diesel	6.9	6.9	6.9	6.9	6.9	6.9

Vocational –gasoline	11.4	11.3	11.3	11.3	11.3	11.3

Vocational – diesel	10.2	10.2	10.2	10.2	10.2	10.2

Comb. tractors	20.2	18.7	18.7	18.7	18.2	18.2



Alternative 4: Engines and Class 7 and 8 Tractors

This alternative combines Alternative 2 with Alternative 3, and
additionally would set an overall vehicle efficiency performance
standard for Class 7 tractors.  This alternative would, thus, set
standards for all HD engines and would set overall vehicle performance
standards for Class 7 and 8 tractors, as described for Class 8
combination tractors under Alternative 3.  Class 7 tractors make up a
small percent of the tractor market, approximately 9 percent.  Though
the segment is currently small, the agencies believe the inclusion of
this class of vehicles would help prevent a potential class shifting, as
noted in the NAS panel report.  

The engine CO2 reductions are described in   REF _Ref267644982 \h  \*
MERGEFORMAT  Table 6-2 , and the road load reductions are described in  
REF _Ref273957504 \h  Table 6-7 .     REF _Ref267645094 \h  \*
MERGEFORMAT  

Table 6-5 .  A separate MOVES run was not performed for this scenario
since it can be taken from Alternative 2 and Alternative 6 (described
below).  The pre-2014 model year inventories were taken from the
baseline run results.  The MY2014+ Class 7/8 combination tractor
inventories were taken from the Alternative 6 run results, and the
MY2014+ numbers for the remainder of the heavy-duty vehicles were taken
from the Alternative 2 results.  It was assumed that 100 percent of
Class 7/8 combination long-haul tractors model year 2014 and later use
APUs during extended idling.  This assumption is based on the
expectation that manufacturers will use APUs to meet the vehicle GHG
standard for combination long-haul tractors.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  7   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  7  Estimated Fleet-Wide Fuel
EfficiencyEconomy by Model Year for Alternative 4 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.6	6.6	6.3	6.3	6.3

HD Pickups and Vans- diesel	6.9	6.9	6.9	6.3	6.3	6.3

Vocational –gasoline	11.4	11.3	11.3	10.8	10.8	10.8

Vocational – diesel	10.2	9.9	9.9	9.9	9.7	9.7

Comb. tractors	20.2	18.5	18.5	18.5	17.9	17.9



Alternative 5: Engines, Class 7 and 8 Tractors, and HD Pickup Trucks and
Vans

This alternative builds on Alternative 4 through the addition of an
overall vehicle efficiency performance standard for HD Pickup Trucks and
Vans (or work trucks).  Therefore, under this alternative, the agencies
would set engine performance standards for each HD vehicle class, and
would also set overall vehicle performance standards for Class 7 and 8
tractors, as well as for HD Pickup Trucks and Vans.  Compliance for the
HD pickup trucks and vans would be determined through a fleet averaging
process similar to determining passenger car and light truck compliance
with CAFE standards.

This is a combination of Alternative 4 with the addition of HD pickup
trucks and vans.  As with Alterative 4, a separate MOVES run was not
performed.  The pre-2014 model year inventories were taken from the
baseline run results.  The MY2014+ Class 7/8 combination tractor and HD
pickup truck and van inventories were taken from the Alternative 6 run
results, and the MY2014+ numbers for the remainder of the heavy-duty
vehicles were taken from the Alternative 2 results.  It was assumed that
100 percent of Class 7/8 combination long-haul tractors model year 2014
and later use APUs during extended idling.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  8   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  8  Estimated Fleet-Wide Fuel
EfficiencyEconomy by Model Year for Alternative 5 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.5	6.5	6.4	6.2	6.0

HD Pickups and Vans- diesel	6.9	6.8	6.7	6.5	6.3	5.9

Vocational –gasoline	11.4	11.3	11.3	10.8	10.8	10.8

Vocational – diesel	10.2	9.9	9.9	9.9	9.7	9.7

Comb. tractors	20.2	18.5	18.5	18.5	17.9	17.9

Alternative 6: Engines, Tractors, and Class 2b through 8 Trucks. 

Alternative 6 represents the agencies’ preferred approach.  This
alternative would set engine efficiency standards, engine GHG emissions
standards, overall vehicle fuel efficiency standards, and overall
vehicle GHG emissions standards for HD pickup trucks and vans and the
remaining Class 2b through Class 8 trucks and the engines installed in
them.  This alternative essentially sets fuel efficiency and GHG
emissions performance standards for both the engines and the overall
vehicles in the entire heavy-duty truck sector.  Compliance with each
vehicle class's engine performance standard would be determined as
discussed in the description of Alternative 2.  Compliance with the
tractor and vocational vehicle classes' overall vehicle performance
standard (Class 3 through 8 trucks) would be determined as discussed in
the description of Alternative 3.  Compliance for the Class 2b and 3
pickup trucks and vans would be determined as described in Alternative
5.

This is the proposed rule.  Details regarding this alternative are
included in Chapter 5.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  9   STYLEREF 1 \s 
6 -  SEQ Table \* ARABIC \s 1  9  Estimated Fleet-Wide Fuel
EfficiencyEconomy by Model Year for Alternative 6 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.5	6.5	6.4	6.2	6.0

HD Pickups and Vans- diesel	6.9	6.8	6.7	6.5	6.3	5.9

Vocational –gasoline	11.4	11.3	11.3	10.7	10.7	10.7

Vocational – diesel	10.2	9.7	9.7	9.7	9.3	9.3

Comb. tractors	20.2	18.5	18.5	18.5	17.9	17.9



The agencies also evaluated two scenarios related to Alternative 6 but
with stringency levels which are 15 percent less stringent and 20
percent more stringent.  These alternatives are referred to as
Alternatives 6a and 6b.

Alternative 6a: Engines, Tractors, and Class 2b through 8 Trucks

Alternative 6a represents an alternative stringency level to the
agencies’ preferred approach.  Like Alternative 6, this alternative
would set GHG emissions and fuel efficiency standards for HD pickup
trucks and vans and for Class 2b through 8 vocational vehicles and
combination tractors and the engines installed in them. The difference
between Alternative 6 and 6a is the level of stringency for each of the
proposed standards.  Alternative 6a represents a stringency level which
is approximately 15 percent less stringent than the preferred approach. 
The agencies calculated the stringency level in order to meet two goals.
 First, we desired to create an alternative that was closely related to
the proposal (within 10-20 percent of the preferred alternative). 
Second we wanted an alternative that reflected removal of the last
technology we believed manufacturers would add in order to meet the
preferred alternative.  In other words, we wanted an alternative that as
closely as possible reflected the last increment in stringency prior to
reaching our preferred alternative.  In general, this could be thought
of as removing the least cost effective (final) step.  Please see Ttable
2.xx35 in RIA Chapter 2 for a list of all of the technologies, their
cost and relative effectiveness. by removing the least cost effective
technology in each of the categories.  The resulting Alternative 6a
standards would isbe based on the same technologies used in Alternative
6 except as follows:

The combination tractor standard would be based removal of the Advanced
SmartWay aerodynamic package and weight reduction technologies which
reduces the average combination tractor savings by approximately 1
percent.  The road load impacts of this alternative are listed in Table
6-10.

The HD pickup truck and van standard would be based on removal of
aerodynamics which reduces the average truck savings by approximately 2
percent.   The estimated total vehicle CO2 reductions for this
alternative are listed in   REF _Ref273958651 \h  Table 6-11 .

The vocational vehicle standard would be based on removal of low rolling
resistant tires which reduces the average vehicle savings by
approximately 2 percent.  

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  10  Estimated
Reductions in Rolling Resistance and Aerodynamic Drag Coefficients from
Reference Case for Alternative 6a (Model Years 2014 and Later)

Truck type	Reduction in tire rolling resistance coefficient from 2010 MY
Reduction in aerodynamic drag coefficient from 2010 MY

Combination long-haul	8.4%	6.1%

Combination short-haul	7.0%	4.6%



Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  11  Estimated
Total Vehicle CO2 Reductions for HD Pickup Trucks and Vans

GVWR class	Fuel	Model years	CO2 Reduction from baseline

LHD 2b-3	Gasoline	2014	1.2%



2015	1.6%



2016	3.2%



2017	4.8%



2018+	8.0%

	Diesel	2014	1.99%



2015	2.6%



2016	5.2%



2017	7.8%



2018+	13.0%

The estimated fleet-wide fuel efficiency for Alternative 6a is listed in
  REF _Ref273960015 \h  Table 6-12 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  12  Estimated
Fleet-Wide Fuel Efficiency by Model Year for Alternative 6a [gallons/100
miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.6	6.5	6.4	6.3	6.1

HD Pickups and Vans- diesel	6.9	6.8	6.7	6.6	6.4	6.0

Vocational –gasoline	11.4	11.3	11.3	10.8	10.8	10.8

Vocational – diesel	10.2	9.9	9.9	9.9	9.7	9.7

Comb. tractors	20.2	18.5	18.5	18.5	17.9	17.9



Alternative 6b: Engines, Tractors, and Class 2b through 8 Trucks

Alternative 6b represents an alternative stringency level to the
agencies’ preferred approach.  Like Alternative 6, this alternative
would set GHG emissions and fuel efficiency standards for HD pickup
trucks and vans and for Class 2b through 8 vocational vehicles and
combination tractors and the engines installed in them. The difference
between Alternative 6 and 6b is the level of stringency for each of the
proposed standards.  Alternative 6ba represents a stringency level which
is 20 percent more stringent than the preferred approach.  The agencies
calculated the stringency level based on similar goals as for
Aalternative 6a.  Specifically, we wanted an alternative that would
reflect an incremental improvement over the preferred alternative based
on the technologies we thought most likely to be applied by
manufacturers if a more stringent standard were set.  In general, this
could be thought of as by adding the next most cost effective technology
in each of the categories.  The agencies developed the alternative
stringencies by adding technologies to the proposed standards.  However,
Aas discussed in the feasibility discussion in Section III, we are not
proposing this level of stringency because we do not believe that these
technologies can be developed and introduced in the timeframe of this
rulemaking.   Reflecting that given unlimited resources it might be
possible to introduce these technologies in this timeframe, but our
inability to estimate what those real costs might be (e.g. to build new
factories in only one to two years), we have denoted the cost for this
alternative with a +c. The +c is intended to make clear that the cost
estimates we are showing do not include additional costs related to
pulling ahead the development and expanding manufacturing base for these
technologies.due to lead time and other issues.  The resulting
Alternative 6b standards would beis based on the same technologies used
in Alternative 6 except as follows:

The combination tractor standard would be based on the addition of
rankine waste heat recovery to the HD engines installed in sleeper
cabscombination tractors with sleeper cabs.  The agencies assumed a 12
kWh waste heat recovery system would reduce CO2 emissions by 6 percent
at a cost of $8,400 per truck.  The agencies applied waste heat recovery
systems to 80 percent of sleeper cabs.  The estimated reduction for this
alternative is included in   REF _Ref273958952 \h  Table 6-13Table 6-13
.

HD pickup truck and van standard would be based on the addition of a 10
percent mass reduction which would increase the average truck savings by
approximately 2 percent over Alternative 6.  The estimated total vehicle
CO2 reductions for this alternative are listed in   REF _Ref273959712 \h
 Table 6-14Table 6-14 .

Vocational vehicle standard would be based on the addition hybrid
powertrains to 8 percent of the vehicles.  The agencies assumed a 25
percent per vehicle GHG emissions and fuel consumption savings due to
the hybrid with a cost of $30,000 per vehicle.  The agencies project the
hybrid penetration for this alternative, as described in   REF
_Ref273959799 \h  Table 6-15Table 6-15 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  13  Estimated
Reductions in Engine CO2 Emission Rates from this Alternative 6b

GVWR class	Fuel	Model years	CO2 Reduction from Reference Case

HHD (8a-8b) – Combination tractors only	Diesel	2014-2016	53%



2017+	86%



Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  14  Estimated
Total Vehicle CO2 Reductions for HD Pickup Trucks and Vans for
Alternative 6b

GVWR class	Fuel	Model years	CO2 Reduction from baseline

LHD 2b-3	Gasoline	2014	1.8%



2015	2.4%



2016	4.8%



2017	7.2%



2018+	12.0%

	Diesel	2014	2.61%



2015	3.4%



2016	6.8%



2017	10.2%



2018+	17.0%



Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  15  Hybrid
Penetration for Vocational Vehicles for Alternative 6b

	MY 2014	MY 2017

Vocational Vehicles	0%	8%



The estimated fleet-wide fuel efficiency for Alternative 6b is listed in
  REF _Ref273960045 \h  Table 6-16 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  16  Estimated
Fleet-Wide Fuel Efficiency by Model Year for Alternative 6b [gallons/100
miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.5	6.5	6.3	6.2	5.8

HD Pickups and Vans- diesel	6.9	6.7	6.7	6.4	6.2	5.7

Vocational –gasoline	11.4	11.3	11.3	10.7	10.7	10.7

Vocational – diesel	10.2	9.7	9.7	9.7	9.1	9.1

Comb. tractors	20.2	18.1	18.1	18.1	17.6	17.6



Alternative 7: Engines, Tractors, Trucks, and Trailers. 

This alternative builds on Alternative 6 by adding a performance
standard for fuel efficiency and GHG emissions of commercial trailers. 
Therefore, this alternative would include fuel efficiency performance
standards and GHG emissions standards for Class 2b and 3 work truck and
Class 3 through Class 8 vocational vehicle engines, and the performance
standards for the overall fuel efficiency and GHG emissions of those
vehicles, as described above.  

This is Alternative 6 with the addition of a regulation of trailers on
combination tractors.  All assumptions are the same as Alternative 6
except for road load.  This alternative would result in further
reductions in drag coefficient and rolling resistance coefficient from
the MY 2010 baseline.    REF _Ref269149500 \h  Table 6-17Table 6-17Table
6-10  describes the road load reductions.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  17   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  10  Estimated Reductions in Rolling
Resistance and Aerodynamic Drag Coefficients from Reference Case for
Alternative 7 (Model Years 2014 and Later)

Truck type	Reduction in tire rolling resistance coefficient from 2010 MY
Reduction in aerodynamic drag coefficient from 2010 MY

Combination long-haul	10.7%	9.2%

Combination short-haul	10.0%	10.6%

Straight trucks, refuse trucks, motor homes, transit buses, and other
vocational vehicles	10.0%	0%

Since the only difference between Alternatives 6 and 7 was the inclusion
of trailers, a MOVES run involving only combination tractors with the
above changes was performed.  For all other heavy-duty vehicles, the
results from Alternative 6 were used for Alternative 7.  The fuel
economy results for Alternative 7 are summarized in   REF _Ref272499293
\h  Table 6-18Table 6-18Table 6-11 .  

The costs for the trailer program of Alternative 7 were derived based on
the assumption that trailer aerodynamic improvements would cost $2,150
per trailer.  This cost assumes side fairings and gap reducers and is
based on the ICF cost estimate.  The agencies applied the aerodynamic
improvement to only box trailers, which represent approximately 60
percent of the trailer sales.  The agencies used $624 per trailer for
low rolling resistance based on the agencies’ estimate of $78 per tire
in the tractor program.  Lastly, the agencies assumed the trailer volume
is equal to three times the tractor volume based on the 3:1 ratio of
trailers to tractors in the market today.  

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  18   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  11  Estimated Fleet-Wide Fuel
EfficiencyEconomy by Model Year for Alternative 7 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.5	6.5	6.4	6.2	6.0

HD Pickups and Vans- diesel	6.9	6.8	6.7	6.5	6.3	5.9

Vocational –gasoline	11.4	11.3	11.3	10.7	10.7	10.7

Vocational – diesel	10.2	9.7	9.7	9.7	9.3	9.3

Comb. tractors	20.2	18.2	18.2	18.2	17.7	17.7



Alternative 8: Engines, Tractors, Trucks, and Trailers with Hybrid
Powertrains 

Alternative 8 includes all elements of Alternative 7, plus the applies
the maximum application of hybrid powertrainss to the pickup trucks,
vans, vocational vehicles, and tractors by the 2014 and the  2017 MY. 
The agencies projectset the hybrid penetration for each class, as
described in   REF _Ref268678194 \h  Table 6-19Table 6-19Table 6-12 . 
The agencies do not believe that it is possible to achieve hybrid
technology penetration rates at or even near these levels in the
timeframe of this rulemaking.  However, we believe it is useful to
consider what a future standard based on the use of such advanced
technologies could achieve.  As with alternative 6b, we include a +c in
our cost estimates for this alternative to reflect additional costs not
estimated by the agencies. The agencies assumed a 25 percent reduction
to CO2 emissions and fuel consumption, based on the findings of the NAS
report.  The agencies also project a cost of $30,000 per vehicle for the
vocational vehicles and combination tractors, which is the median value
described in the NAS report for the vocational vehicles and tractors. 
The agencies are projecting a cost of $9,000 per vehicle for the HD
pickup trucks and vans, again based on the NAS report.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  19   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  12 : Hybrid Penetration by Vehicle Class

	MY 2014	MY 2017

HD Pickup Trucks & Vans	10,000 units	50%

Vocational Vehicles	10,000 units	50%

Combination tractors	0%	0%

Since the only difference between Alternatives 7 and 8 was the
penetration of hybrid technology in the vocational vehicle and HD pickup
and van categories, a MOVES run involving only vocational vehicles and
HD pickups and vans was performed.  In vocational vehicles, EPA assumed
that hybrid technology would be applied only in diesel-fueled trucks. 
In HD pickups and vans, EPA assumed that hybrid technology would be
evenly divided between diesel and gasoline vehicles.  The fuel economy
results for Alternative 8 are summarized in   REF _Ref272500526 \h 
Table 6-20Table 6-20Table 6-13 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  20   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  13  Estimated Fleet-Wide Fuel
EfficiencyEconomy by Model Year for Alternative 8 [gallons/100 miles]

	MY 2010-2013	MY 2014	MY 2015	MY 2016	MY 2017	MY 2018

HD Pickups and Vans - gasoline	6.7	6.5	6.5	6.4	5.5	5.2

HD Pickups and Vans- diesel	6.9	6.8	6.7	6.5	5.5	5.1

Vocational –gasoline	11.4	11.3	11.3	10.7	10.7	10.7

Vocational – diesel	10.2	9.6	9.6	9.6	8.0	8.0

Comb. tractors	20.2	18.2	18.2	18.2	17.7	17.7



How Do These Alternatives Compare in Overall GHG Emissions Reductions
and Fuel Efficiency and Cost?

The agencies analyzed all seven alternatives through MOVES to evaluate
the impact of each proposed alternative, as shown in   REF _Ref266865355
\h  Table 6-21Table 6-14    REF _Ref274138529 \h  Table 6-21 .  The
table contains both the total savings for each alternative, along with
the contribution from each truck class.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  21   STYLEREF 1
\s  6 -  SEQ Table \* ARABIC \s 1  14 : Annual CO2 and Oil Savings in
2030 and 2050

	Downstream CO2 Savings (MMT)	Oil Savings (billion gallons)

	2030	2050	2030	2050

Alt. 1	0	0	0	0







Alt. 2 - Total	29	46	2.9	4.6

Tractors	19	27	1.8	2.6

HD Pickup Trucks	4	7	0.4	0.7

Vocational Vehicles	6	13	0.6	1.2







Alt. 3 – Total	35	50	3.4	4.9

Tractors	35	50	3.4	4.9

HD Pickup Trucks	0	0	0	0

Vocational Vehicles	0	0	0	0







Alt. 4 – Total	50	76	5.0	7.5

Tractors	40	57	3.9	5.6

HD Pickup Trucks	4	7	0.4	0.7

Vocational Vehicles	6	13	0.6	1.2







Alt. 5 – Total	54	82	5.4	8.2

Tractors	40	57	3.9	5.6

HD Pickup Trucks	8	13	0.8	1.3

Vocational Vehicles	6	13	0.6	1.2







Alt. 6a – Total	5052	7779	5.01	7.8

Tractors	3539	5056	3.86	5.15

HD Pickup Trucks	7	11	0.7	1.1

Vocational Vehicles	86	1613	0.86	1.61.2







Preferred – Total	58	91	5.8	9.0

Tractors	40	57	3.9	5.6

HD Pickup Trucks	8	13	0.8	1.3

Vocational Vehicles	10	21	1.0	2.1







Alt. 6b – Total	7068	110107	7.16.7	11.110.6

Tractors	4846	6865	4.84.5	6.86.4

HD Pickup Trucks	9	15	1.0	1.6

Vocational Vehicles	13	27	1.3	2.6







Alt. 7 - Total	62	96	6.1	9.5

Tractors	40	57	3.9	5.6

HD Pickup Trucks	8	13	0.8	1.3

Vocational Vehicles	10	21	1.0	2.1

Trailers	4	5	0.4	0.5







Alt. 8 - Total	86	142	8.4	14.2

Tractors	40	57	3.9	5.6

HD Pickup Trucks	16	25	1.6	2.7

Vocational Vehicles	26	55	2.5	5.4

Trailers	4	5	0.4	0.5

The aggregate technology costs for each alternative are included in  
REF _Ref267579535 \h  Table 6-22Table 6-22Table 6-15 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  22   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  15 : Technology Cost Projections for the
Alternativesa

	Technology costs (2008$ millions)

	2030	2050

Alt. 1	$0	$0





Alt. 2 - Total	$532 	$749 

Tractors	$119 	$157 

HD Pickup Trucks	$235 	$273 

Vocational Vehicles	$178 	$319 

	 	 

Alt. 3 – Total	$669 	$885 

Tractors	$669 	$885 

HD Pickup Trucks	$0 	$0 

Vocational Vehicles	$0 	$0 

	 	 

Alt. 4 – Total	$1,114 	$1,519 

Tractors	$701 	$927 

HD Pickup Trucks	$235 	$273 

Vocational Vehicles	$178 	$319 

	 	 

Alt. 5 – Total	$1,833 	$2,356 

Tractors	$701 	$927 

HD Pickup Trucks	$954 	$1,110 

Vocational Vehicles	$178 	$319 

	 	 

Alt. 6a – Total	$1,543	$1,978

Tractors	$445	$590

HD Pickup Trucks	$919	$1,069

Vocational Vehicles	$178	$319





Preferred – Total	$1,896 	$2,473 

Tractors	$701 	$927 

HD Pickup Trucks	$954 	$1,110 

Vocational Vehicles	$241 	$436 

	 	 

Alt. 6b – Total	$4,900+c	$7,470+c

Tractors	$1,333+c	$1,764+c

HD Pickup Trucks	$1,259+c	$1,465+c

Vocational Vehicles	$2,307+c	$4,241+c





Alt. 7 - Total	$2,806 	$3,676 

Tractors	$701 	$927 

HD Pickup Trucks	$954 	$1,110 

Vocational Vehicles	$241 	$436 

Trailers	$910 	$1,203 

	 	 

Alt. 8 - Total	$35,428 +c	$58,936+c 

Tractors	$701 	$927 

HD Pickup Trucks	$7,752 +c	$8,800+c

Vocational Vehicles	$26,065+c	$48,006+c

Trailers	$910 	$1,203 

a The +c is intended to make clear that the cost estimates we are
showing do not include additional costs related to pulling ahead the
development and expanding manufacturing base for these technologies.

The downstream impacts of NOx, CO, PM, and VOC emissions for each of the
primary alternatives are included in   REF _Ref272317607 \h  Table
6-23Table 6-23Table 6-16 .

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  23   STYLEREF 1 \s
 6 -  SEQ Table \* ARABIC \s 1  16  Downstream Impacts Relative to
Alternative 1 of Key Non-GHGs for Each Alterative in 2030

	NOx	co	pm2.5	VOC

Alt. 1	0%	0%	0%	0%

Alt. 2	0.60%	0.32%	0.47%	-0.26%

Alt. 3	-20.2%	-2.3%	6.8%	-17.1%

Alt. 4	-20.5%	-2.0%	7.4%	-17.5%

Alt. 5	-20.5%	-2.0%	7.4%	-17.6%

Alt. 6a	-20.5%	-2.0%	7.4%	-17.65%

Preferred	-20.6%	-2.0%	7.4%	-17.7%

Alt. 6b	-20.8%	-2.0%	7.34%	-17.89%

Alt. 7	-20.9%	-2.0%	7.3%	-17.8%

Alt. 8	-20.9%	-2.0%	7.3%	-17.8%





References

Draft Regulatory Impact Analysis 	

Heavy-Duty GHG and Fuel Efficiency Standards NPRM: Results of Proposed
and Alternative Standards

  PAGE  6-20 

  PAGE  6-21 

 NEPA requires agencies to consider a “no action” alternative in
their NEPA analyses and to compare the effects of not taking action with
the effects of the reasonable action alternatives to demonstrate the
different environmental effects of the action alternatives.  See 40 CFR
1502.2(e), 1502.14(d).CEQ has explained that “[T]he regulations
require the analysis of the no action alternative even if the agency is
under a court order or legislative command to act. This analysis
provides a benchmark, enabling decision makers to compare the magnitude
of environmental effects of the action alternatives. It is also an
example of a reasonable alternative outside the jurisdiction of the
agency which must be analyzed. [See 40 CFR 1502.14(c).] * * * Inclusion
of such an analysis in the EIS is necessary to inform Congress, the
public, and the President as intended by NEPA. [See 40 CFR 1500.1(a).]''
Forty Most Asked Questions Concerning CEQ's National Environmental
Policy Act Regulations, 46 FR 18026 (1981) (emphasis added).

 There are several reasons for this approach. In many cases the engine
and chassis are produced by different manufacturers and it is more
efficient to hold a single entity responsible. Also, testing an engine
cell is more accurate and repeatable than testing a whole vehicle.

 See the MD/HD NAS Report for discussions of the potential fuel
efficiency improvement technologies that can be applied to each of these
vehicle components. MD/HD NAS Report, supra note 9, Chapter 5.

 MJ Bradley.  Heavy Duty Market Analysis.  2009.

 NAS.  Page 152.

 TIAX.  2009.  Page 4-20.

 NAS Report.  Page 146.

 NAS Report.  Page 146.

 NAS Report.  Page 146.

